(Residents of the European Union)
For Customers who are natural persons residing in the European Union (hereinafter “EU”), there may be additional rights provided in Regulation (EU)2016/679, commonly known as the “General Data Protection Regulation” (hereinafter “GPDR”), effective 25 May 2018, as it pertains to protection of “personal data” of natural persons domiciled in the EU. “Personal data” in the GPDR essentially means information by which one might directly or indirectly ascertain the actual identity, location, etc., of a customer of SCE. For our purposes here, “EU” may include non-EU nations that are members of the European Economic Area (EEA).
SCE gathers information from customers and potential customers with their consent that specifically relates to their purchase of single- or multi-player Internet games, and such ancillary activities as chat-rooms for multi-player games. SCE does not sell or distribute such information, excepting for such consented-to activities such as the use of third-party financial institutions and billing services (e.g., PayPal, Bluesnap, etc.) A customer’s consent may be withdrawn at any time, excepting for certain situations as narrowly described in the GPDR. SCE does not willfully accept such “consent” from customers or would-be customer under the age of 16 without the explicit consent of a parent or guardian, and is particularly amenable to correction where the customer had been under that age at the time they became a customer
Customers have the right to seek from SCE, upon adequate proof of their own identity, identification of such personal data of themselves, the correction of any errors therein, or deletion, subject to certain GPDR exclusions. Note that in some instances the data sought to be identified, corrected, or deleted may be more appropriately found with a third-party, such as a billing agent or channel partner; in such instance SCE will assist insofar as possible but may also direct the customer appropriately. Said third parties consent to comply with, and assist SCE in its compliance with, the GPDR.
Overall, it is SCE’s policy that personal data be handled lawfully, fairly, with transparency, in a portable fashion, and for legitimate business purposes only. EU customers may have additional rights or remedies granted, such as from national authorities in their member state. SCE will continue to develop procedures in compliance with the GPDR, with the advice and consent of such authorities the GPDR may designate for that purpose.
1. Under applicable law, Silver Creek Entertainment (“SCE” or “we”, “us” etc.) is the “controller” (as that term is used in the GPDR) of personal data collected through our services.
2. When you interact with us, we may collect information from you, as follows:
a. What You Tell us Directly: We collect information from you when you voluntarily provide such information, such as when you register for access to our services or use certain Services. Information we collect may include but not be limited to username, email address, and any messages, images, transient VOIP data (to enable communication delivery only) or such information you provide in the course of game play or chat.
b. What We Collect Automatically: When you interact with us through our services, we receive and store certain information such as an IP address, device ID, and your activities within our services. We may store such information or such information may be included in databases owned and maintained by affiliates, agents or service providers. Our services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of messages users have sent, as well as the sites which refer visitors to SCE.
c. Aggregated Information: In an ongoing effort to better understand and serve the users of our services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
d. Info through other Services: You may give us permission to collect your information in other services. For example, you may connect a social networking service ("SNS") such as Facebook or Twitter to your SCE account. When you do this, it allows us to obtain information from those accounts (for example, your friends or contacts).
f. Advertisements: You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and installing our Service, you will become a user of the Service. Sometimes advertising involves the collection of personal data when a user or potential user ‘clicks’ such advertising. SCE does not offer a “Do Not Track” option directly. However, you may “opt out” of personalized advertising delivered by third parties through programs that are administered by certain third parties, including the Digital Advertising Alliance or Network Advertising Initiative.
3. Processors. SCE is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may or may not be as comprehensive or protective as the laws of the EU or EU member-state where you live. However, it is the intention of SCE to comply as far as possible with the laws of whichever jurisdiction provides the maximum privacy protection, and to ensure to our best ability that processors and other third parties also respect your privacy.
4.Our Use of Your Personal Data. When you provide us information for a certain reason, we may use the information in connection with the reason for which it was provided. SCE or affiliates may also use your information collected through our services to help us improve the content and functionality of our services, to better understand our users and to improve our services. We may also use such information for marketing purposes, subject however, to your right to “opt out” as described above, or your right to instruct us to remove you from our mailing list. We may also use personal data for customer service, to maximize user experience, to optimize the service with improvements and advise you of such improvements, for the protection of users, or pursuant to legal requirements or process. And, of course, we may use where the user consents, expressly or impliedly. We consider unsolicited information to be information that the discloser consents to use or release.
5.SCE does not sell personal data. However, there are some circumstances where sharing or transfer may occur, such as business reorganization, outside developers or necessary transactions with affiliated companies, channel partners, outside agents or consultants, or the like. There may also be legal obligations arising where such is reasonably necessary for our compliance.
6. Links on our site to unrelated sites do not constitute any representation or guarantee that such other sites are compliant with SCE or the EU’s privacy policies
7. We do not knowingly do business with minors. A “minor” for purposes here is anyone under the age of 16, except in such EU member states where a lower age of consent has been established, but in no event under the age of 13. In the event that you are a parent or guardian of a minor and you have reason to believe that personal information has been disclosed by that minor to SCE, please contact us at the address indicated below, so that we may take corrective action.
8. Retention and Security. We retain for as long as is reasonably necessary for our purposes, subject to backup or other legitimate business procedures. We may take steps to delete or “anonymize” (render not easily identifiable to an actual person by casual inspection.)
Security is to a large degree the responsibility of the individual user. In addition, however, SCE takes reasonable steps to protect any data in our control from access or misuse by unauthorized parties.
9. We may periodically modify this. Please check back from time to time.
10. May reach us concerning your privacy rights, or you just want us to delete everything, please contact us at the following address: firstname.lastname@example.org. For deleting everything, you may request that at that address; we will respond by sending you a link. Please note that the link sent to you will require authenticating information (so we know it is really you) and note also that when we delete everything, it is permanent, i.e., we cannot “undelete” it.
Thank you for your business!